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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made <br />during the inspection. Comments also describe any enforcement actions taken during the inspection <br />and the facts or evidence supporting the enforcement action. <br />during the first couple growing seasons, vegetation community development toward the <br />desired conditions will likely be a slow process. <br />Cheatgrass is still a significant component of the vegetation stand on the reclaimed RP-1 <br />Refuse Area, dominant over much of the site. Perennial grasses are present in most areas, <br />but grasses made poor growth this year due to dry conditions, and the extent.of perennial <br />grass cover was difficult to assess due to short stature and dormant condition of the <br />grasses. Shrubs are very sparse and half shrubs and (orbs largely absent from the stand. <br />Additional subsoil was spread on the top of the RP-5A subsoil stockpile 3-4 years ago, and <br />the area was seeded with a relatively diverse seedmix including grasses, shrubs, half-shrubs <br />and forbs. In most areas, the stand is dominated by aggressive grasses including crested <br />wheatgrass, Russian wildrye, and western wheatgrass, with cheatgrass also present. Shrub <br />establishment is very sparse and half-shrubs/forbs essentially absent. However, a strip <br />through the center of the parcel was seeded with the grass component excluded. Within <br />this strip, shrub density was markedly higher, and included big sagebrush, tour-wing <br />saltbush, and greasewood, along with scattered winterfat (a half-shrub). <br />Several of the laydown areas that were reclaimed in the 1980's are dominated by <br />aggressive grasses including crested wheatgrass and Russian wildrye, with low diversity <br />and minimal shrub/half-shrub/forb component. <br />Retreatment of various revegetated stands including RP-1 and certain of the laydown areas <br />would appear to be warranted to achieve desired woody plant density levels and to <br />incorporate ahalf-shrub/forb component. Tilling up patches or strips within the established <br />low diversity grass stands, and seeding with a mix that includes only native shrubs, half- <br />shrubs, and forbs, and non-competitive native grasses such as bluebunch wheatgrass may <br />be a practicable approach to enhance the shrub density and diversity of these stands. It is <br />recommended that the operator consider the allowances and restrictions regarding <br />interseeding included in current Rule 4.15.715) and proposed Rule 4.15.715)lg) [of the <br />Division's March 2003 Formal State Program Amendment submittal to OSMI• Revision of <br />the initial seeding practices to incorporate strip or patch seeding of shrubs, half-shrubs, <br />forbs, and possibly low competitive grass species may also be warranted, to enhance shrub <br />establishment and diversity within initial seedings. This approach is being used with <br />generally good results at several of the surface mines in Moffat and Routt County, and the <br />results observed on the RP-5A subsoil stockpile would suggest that the approach might be <br />successful at Deserado. <br />An additional issue that Scott Wanstedt brought up was his concern that neither the <br />Colorado Wildrye nor big sagebrush reference areas adequately represented the harsh slope, <br />aspect, and potential vegetative community of the East Portal Ventilation Entry and Access <br />Road reclamation area. The steep south facing slope immediately above the disturbed area <br />is a relative sparse sagebrush/shadscale community. Slope and aspect of this community is <br />very comparable to the reclaimed area, and submittal of a revision application to justify and <br />incorporate an additional reference area encompassing the undisturbed portions of this slope <br />